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Saturday, January 7, 2017

U.S. Embargoes Egyptian Coins among other artifacts

by Peter Tompa
December 22, 2016 - The U.S. Government has published an extensive list of artifacts
subject to import restrictions pursuant to a Memorandum of
Understanding (MOU) with Egypt. The effective date of the regulations is
December 5, 2016.

The Designated List

The designated list
restricts entry of all ancient coin types down to 294 AD. Roman
Imperial, Byzantine and Ottoman coins struck at Roman mints after that
date do not seem to be impacted. The complete list is as follows:
H. CoinsIn copper or bronze, silver, and gold.
1. General – There are a number of references that list Egyptian coin
types. Below are some examples. Most Hellenistic and Ptolemaic coin
types are listed in R. S. Poole, A Catalogue of Greek Coins in the
British Museum: Alexandria and the Nomes (London, 1893); J. N. Svoronos,
Münzen der Ptolemäer (Athens 1904); and R. A. Hazzard, Ptolemaic Coins:
An Introduction for Collectors (Toronto, 1985). Examples of catalogues
listing the Roman coinage in Egypt are J. G. Milne, Catalogue of
Alexandrian Coins (Oxford, 1933); J. W. Curtis, The Tetradrachms of
Roman Egypt (Chicago, 1969); A. Burnett, M. Amandry, and P. P Ripollès,
Roman Provincial Coinage I: From the Death of Caesar to the Death of
Vitellius (London, 1998 – revised edition); and A. Burnett, M. Amandry,
and I. Carradice, Roman Provincial Coinage II: From Vespasian to
Domitian (London, 1999). There are also so-called nwb-nfr coins,
which may date to Dynasty 30. See T. Faucher, W. Fischer-Bossert, and S.
Dhennin, “Les Monnaies en or aux types hiéroglyphiques nwb nfr,”
Bulletin de l’institut français d’archéologie orientale 112 (2012), pp.
147-169.
2. Dynasty 30 – Nwb nfr coins have the hieroglyphs nwb nfr on one side and a horse on the other.
3. Hellenistic and Ptolemaic coins – Struck in gold, silver, and
bronze at Alexandria and any other mints that operated within the
borders of the modern Egyptian state. Gold coins of and in honor of
Alexander the Great, struck at Alexandria and Memphis, depict a helmeted
bust of Athena on the obverse and a winged Victory on the reverse.
Silver coins of Alexander the Great, struck at Alexandria and Memphis,
depict a bust of Herakles wearing the lion skin on the obverse, or
“heads” side, and a seated statue of Olympian Zeus on the reverse, or
“tails” side. Gold coins of the Ptolemies from Egypt will have jugate
portraits on both obverse and reverse, a portrait of the king on the
obverse and a cornucopia on the reverse, or a jugate portrait of the
king and queen on the obverse and cornucopiae on the reverse. Silver
coins of the Ptolemies coins from Egypt tend to depict a portrait of
Alexander wearing an elephant skin on the obverse and Athena on the
reverse or a portrait of the reigning king with an eagle on the reverse.
Some silver coins have jugate portraits of the king and queen on the
obverse. Bronze coins of the Ptolemies commonly depict a head of Zeus
(bearded) on the obverse and an eagle on the reverse. These
iconographical descriptions are non-exclusive and describe only some of
the more common examples. There are other types and variants.
Approximate date: ca. 332 B.C. through ca. 31 B.C.
4. Roman coins – Struck in silver or bronze at Alexandria and any
other mints that operated within the borders of the modern Egyptian
state in the territory of the modern state of Egypt until the monetary
reforms of Diocletian. The iconography of the coinage in the Roman
period varied widely, although a portrait of the reigning emperor is
almost always present on the obverse of the coin. Approximate date: ca.
31 B.C. through ca. A.D. 294.
Thus far the official list.

Not
all coins from Roman Alexandria have such an impeccable provenance as
this one, which comes from the Dattari collection. From Künker 280
(2016), 590.

Under U.S. Customs procedures, the above coin types
can only be imported into the U.S. with documentation certifying they
were out of Egypt before the effective date of the restrictions. As time
goes on, this becomes far more difficult to do because the vast
majority of ancient Egyptian coins legally available for sale and export
in markets in Europe lack the necessary provenance information for
legal import into the U.S.

Concerns and Controversies

The
decision raises several concerns both generally and specifically as to
coins. As early as 2011, Zahi Hawass, then Egypt’s Antiquities minister,
reported on his blog in a now deleted post that a “coalition [of U.S.
archaeological groups] reported that the US Government is willing to
impose emergency restrictions on Egyptian antiquities....The coalition
will be drafting a formal agreement between the US and Egyptian
governments....” Additional reports that the matter was already a “done
deal” surfaced even before a 2014 U.S. Cultural Property Advisory
Committee meeting was announced to process the request. For example, a
New York Times editorial, dated March 20, 2014, indicated that the U.S.
had already agreed to import restrictions to stem the flow of objects
looted during Egypt’s revolution. Then, however, the fallout from an
Egyptian military coup evidently put such restrictions on hold until
late in the Obama Administration. The decision was announced less than
two months after Evan Ryan, Assistant Secretary of State, Bureau of
Educational Affairs (ECA), received an award
from the Archaeological Institute of America (AIA). In the author’s
view, Ryan’s acceptance of the award raises serious conflict of interest
issues, if not a violation of ethics rules concerning the acceptance of
gifts and awards. The AIA lobbied heavily for a MOU with Egypt, and the
AIA’s award to Ryan specifically referenced ECA’s work in implementing MOU’s.
The governing statute, the Convention on Cultural Property
Implementation Act (CPIA), only allows the government to restrict
artifacts “first discovered within” and hence “subject to export control
by” of Egypt. See 19 U.S.C. Sections 2601, 2604. With regard to coins,
the State Department evidently ignored evidence that demonstrates that
Egyptian mint coins are regularly discovered outside of Egypt. Egypt’s
so-called “closed monetary system” was meant to keep foreign coins “out”
and not Egyptian coins “in.” Hoard evidence confirms Ptolemaic coins
from Egyptian mints circulated throughout the Ptolemaic Empire which
stretched well beyond the confines of modern-day Egypt. (And, indeed,
some hoards are found outside the Empire’s territory.) The State
Department also ignored finds reported under the U.K.’s Portable
Antiquities Scheme that show Roman Egyptian Tetradrachms circulated as
far away as Roman Britain.However, it is the wording of the
restrictions themselves that should cause the greatest concern. Despite
the CPIA’s “first discovered within” requirement, the regulations
imposing import restrictions are based on place of manufacture rather
than find spot. Accordingly, the new restrictions appear to create an
embargo on all designated coin types based on where they were made
thousands of years ago rather than where they are found today. In
contrast, the CPIA itself only authorizes import restrictions on coins
that were illegally removed from Egypt after the date that restrictions
were imposed. Restrictions drafted with administrative convenience
in mind rather than fidelity to the law cause considerable collateral
damage. Due to their wording, small businesses of the numismatic trade
and collectors risk detention, seizure and forfeiture of designated
Egyptian coin types legally exported from Europe. Many historical coins
on the market and in collections abroad simply can’t meet the law’s
stringent provenance requirements for legal import. American
collectors should only purchase their coins from reputable dealers.
Before importing coins from abroad, confirm that the seller abroad is
able to provide the necessary paperwork for a legal import. Going
forward, the author hopes the new Administration will take a hard look
at current State Department and Customs practices. Efforts to protect
cultural patrimony cannot be allowed to justify the taking of private
property without due process of law.